1. Definitions
The following terms have the meanings set forth below when used in this Privacy Policy. Other capitalized terms used but not defined here have the meanings given in our Terms & Conditions.
"Authorized User" means an individual designated by a Customer to access and use the Platform on Customer's behalf.
"BitGo" or "Custodian" means BitGo Bank & Trust, National Association, the custodian providing custody, settlement, and regulated financial services in connection with the Platform.
"Customer" means the entity identified in an applicable Order Form that has entered into an agreement with TBMC for use of the Services.
"Customer Data" means data submitted by a Customer to the Platform, excluding Transaction Data.
"Personal Information" means information that identifies, relates to, or could reasonably be linked to a particular individual, including names, email addresses, government-issued identification numbers, and other information described in Section 3 of this Privacy Policy.
"Platform" means TBMC's proprietary stablecoin clearinghouse technology platform, including all APIs, interfaces, dashboards, and related tools.
"Services" means the stablecoin swapping, clearing facilitation, and related services provided through the Platform as described in the applicable Order Form.
"Transaction Data" means data related to a Customer's Transactions, including amounts, asset types, wallet addresses, timestamps, and chain identifiers.
2. Introduction
This Privacy Policy describes how The Better Money Company, a Delaware corporation ("TBMC," "we," "us," or "our"), collects, uses, discloses, and protects information in connection with the Services, our website, and our other interactions with you.
We provide this Privacy Policy as a notice of our data practices. Where applicable law requires your consent for specific processing activities, we will obtain that consent separately. By using the Services, accessing our website, or submitting information to us, you acknowledge that you have read and understand the practices described in this Privacy Policy.
This Privacy Policy does not apply to services provided by BitGo or any other third party. Customer's relationship with BitGo is governed by the BitGo Customer Agreements and BitGo's own privacy policy. We encourage you to review BitGo's privacy practices separately.
3. Information We Collect
We collect information in the following categories:
3.1 Business Identification and Onboarding Information
When Customer applies for an account, we collect information necessary to perform know-your-business ("KYB"), know-your-customer ("KYC"), anti-money laundering, and sanctions screening. This may include:
- Entity name, entity type, jurisdiction of formation, and business address
- Employer Identification Number (EIN) or other tax identification numbers
- Formation and organizational documents (e.g., articles of incorporation, operating agreements)
- Names, addresses, dates of birth, and Social Security numbers of beneficial owners, officers, directors, and authorized signatories
- Government-issued identification documents (e.g., passports, driver's licenses) of beneficial owners and Authorized Users
- Information about Customer's business activities, ownership structure, and regulatory status
3.2 Account and Contact Information
We collect names, email addresses, phone numbers, and other contact details for Authorized Users and Customer representatives.
3.3 Transaction Data
We collect data related to Customer's Transactions, including amounts, asset types, wallet addresses, memos, timestamps, chain identifiers, and certain recipient information.
3.4 Customer Data
We collect other data that Customer submits to the Platform in connection with the Services.
3.5 Device and Technical Information
When you access the Platform or our website, we may automatically collect IP addresses, browser type and version, device identifiers, operating system information, access times, and log data.
3.6 Communications
We collect information contained in communications between you and TBMC, including support requests, emails, and other correspondence.
3.7 Information from Third Parties
We may receive information about Customer from third-party sources, including identity verification providers, sanctions and watchlist screening services, public records, and the Custodian.
3.8 Job Applicant Information
If you apply for a position at TBMC, we collect information you provide in connection with your application, including your name, email address, resume or CV, employment history, and any other information you choose to submit.
3.9 Website Visitor and Marketing Information
If you sign up for our blog distribution list, product waitlist, or other marketing communications, or submit a form on our website, we collect the information you provide, which typically includes your name and email address.
4. How We Use Information
We use the information we collect for the following purposes:
- Providing the Services. To operate the Platform, process Transactions, manage Customer accounts, and perform our obligations under the Terms of Service and applicable Order Forms.
- Onboarding and Verification. To verify Customer's identity, conduct KYB and KYC checks, screen against sanctions lists, and perform ongoing due diligence as required by applicable law.
- Compliance and Legal Obligations. To comply with applicable law, including anti-money laundering and sanctions requirements; to file suspicious activity reports (SARs) or other regulatory reports; to detect, investigate, and respond to fraud; and to respond to subpoenas, court orders, or other lawful requests from governmental authorities.
- Security and Fraud Prevention. To detect, investigate, and prevent fraud, unauthorized access, and other illegal or suspicious activity; to monitor Transactions for compliance; and to protect the integrity of the Platform.
- Communicating with You. To send service-related notices, respond to inquiries, provide customer support, and send marketing or informational communications to individuals who have opted in to receive them (such as blog updates or product waitlist notifications). You may unsubscribe from marketing communications at any time by following the unsubscribe instructions in any such communication or by contacting us at privacy@bettermoney.com.
- Improving the Services. To analyze usage patterns, troubleshoot issues, and improve the Platform's functionality, performance, and security.
- Evaluating Job Applicants. To assess and process job applications, communicate with applicants about open positions, and make hiring decisions.
- Aggregated and De-Identified Data. To create aggregated or de-identified data that does not identify any individual for analytics, reporting, and other lawful business purposes.
- Enforcing Our Rights. To enforce our Terms of Service, protect our rights and property, and pursue available remedies.
5. How We Share Information
We do not sell your information. We may share information in the following circumstances:
5.1 Custodian
We share Customer information, including onboarding data, identity verification data, beneficial ownership information, and Transaction Data, with BitGo Bank & Trust, National Association as necessary for BitGo to perform its custodial, settlement, compliance, and related obligations. BitGo's use of this information is governed by the BitGo Customer Agreements and BitGo's own privacy practices.
5.2 Service Providers
We share information with third-party service providers that assist us in operating the Platform, performing the Services, and running our business, including:
- Identity verification and KYB/KYC providers (e.g., Persona Identities, Inc.)
- Sanctions screening and compliance monitoring providers
- Compliance vendors
- Cloud hosting and infrastructure providers
- Analytics and monitoring tools
- Email delivery and marketing communication providers
Our service providers are contractually obligated to use information only as necessary to provide services to TBMC and to maintain appropriate confidentiality and security safeguards.
5.3 Governmental Authorities
We may disclose information to regulators, law enforcement, or other governmental authorities as required by applicable law, in response to subpoenas, court orders, or other lawful process, or as we reasonably determine is necessary to comply with our legal or regulatory obligations. This includes, without limitation, the filing of SARs and other reports that TBMC is prohibited by law from disclosing to Customer.
5.4 Legal Proceedings
We may disclose information in connection with actual or potential litigation, arbitration, or other legal proceedings to protect our rights or the rights of others.
5.5 Business Transfers
In connection with any merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, information we have collected may be transferred to the acquiring or successor entity.
5.6 With Your Consent
We may share information for other purposes with your prior consent.
5.7 Aggregated or De-Identified Data
We may share aggregated or de-identified data that does not identify any individual with third parties for any lawful business purpose.
6. Identity Verification
As part of our onboarding and ongoing compliance processes, we use Persona Identities, Inc. ("Persona") to verify the identity of beneficial owners and Authorized Users. Persona may process government-issued identification documents and, where applicable, facial images to perform identity verification and fraud prevention. Persona's processing of this information is governed by Persona's privacy policy, available at https://withpersona.com/legal/privacy-policy. TBMC receives verification results from Persona but does not directly receive or store biometric data generated by Persona.
7. Cookies and Tracking Technologies
We use cookies, web beacons, and similar tracking technologies on our website and Platform to collect usage information, analyze trends, and improve the Services. We may use third-party analytics tools and services to help us understand how visitors interact with our website. These technologies collect information such as pages visited, time spent on pages, referring URLs, browser type and device identifiers, and general location data. We use this information to analyze usage trends and improve the functionality and performance of our website and Services. You can manage or disable cookies through your browser settings. Please note that disabling cookies or opting out oftracking may affect the functionality of our website or certain features of the Services.
8. Data Security
TBMC maintains commercially reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, loss, destruction, or alteration. These safeguards include encryption, access controls, and secure infrastructure. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. Customers are responsible for maintaining the security of their own account credentials, as described in the Terms of Service.
9. Data Retention
We retain information for as long as necessary to fulfill the purpose for which it was collected, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
Although TBMC is not a money services business and is not subject to Bank Secrecy Act obligations, we have voluntarily adopted data retention practices consistent with the standards applicable to such entities and to ensure Custodians have the information necessary to fulfill their regulatory obligations. The following retention periods apply:
9.1 Customer Identification and KYB Records.
We retain customer identification, KYB, and beneficial ownership records for at least five (5) years after account closure, consistent with the standards set forth in 31 CFR Chapter X.
9.2 Transaction Records
We retain records of funds transmittals of $3,000 or more for at least five (5) years, consistent with the standards set forth in 31 CFR § 1010.410.
9.3 Suspicious Activity Reports and Investigation Files
We retain filed SARs and all supporting documentation for at least five (5) years from the date of filing, consistent with the standards set forth in 31 CFR § 1022.320. Non-SAR investigation files are retained for at least five (5) years from the conclusion of the investigation.
9.4 Sanctions and OFAC Records
We retain records relating to blocked or rejected property and other OFAC-related documentation for at least ten (10) years, consistent with the standards set forth in 31 CFR § 501.601.
9.5 Fraud Records
We retain fraud investigation records for at least five (5) years from SAR filing (for fraud-related SARs) or five (5) years from investigation conclusion (for non-SAR files). Our Fraud Loss Register is maintained indefinitely as a cumulative dataset.
9.6 Employee and Training Records
We retain employee records for at least five (5) years after separation and training materials and attendance records for at least five (5) years.
9.7 Custodian Requirements
We may also retain information as necessary to comply with BitGo's data retention policies and requirements, which may change from time to time. Where BitGo's retention requirements exceed those described above, we will retain the relevant information for the longer period.
9.8 Job Applicant Information
We retain job applicant information for a reasonable period following the conclusion of the hiring process, unless a longer retention period is required or permitted by law.
9.9 Marketing and Waitlist Information
We retain your name and email address for as long as you remain subscribed to our communications. If you unsubscribe, we will delete your information within a reasonable period, except as necessary to maintain a suppression list to honor your opt-out preference.
9.10 General
Where applicable law or our contractual obligations require a longer retention period than those described above, we will retain the relevant information for the longer period. Aggregated or de-identified data that does not identify any individual may be retained indefinitely for analytics and business purposes.
10. Your Rights
You may request access to, correction of, or deletion of your Personal Information by contacting us at privacy@bettermoney.com. We will respond to your request within a reasonable timeframe and in accordance with applicable law.
Certain information may be exempt from such requests under applicable law. For example, we may be required to retain certain records to comply with anti-money laundering regulations, sanctions requirements, or other applicable law, or to comply with BitGo's data retention requirements. In those cases, we will inform you of the reason we cannot fulfill your request. We will not discriminate against you for exercising any of these rights.
If you have subscribed to marketing communications, you may opt out at any time by following the unsubscribe instructions in any such communication or by contacting us at privacy@bettermoney.com.
11. Third-Party Practices
This Privacy Policy applies only to TBMC. It does not cover the practices of BitGo Bank & Trust, National Association, any Stablecoin issuer, blockchain networks, or other third parties. Your use of third-party services, including BitGo's custodial services, is subject to those third parties' own privacy policies and terms. We encourage you to review the privacy practices of any third party with which you interact in connection with the Services.
12. Children's Information
The Services are designed for use by business entities and are not directed to individuals under the age of 18. We do not knowingly collect information from individuals under 18. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it promptly.
13. International Use
TBMC currently operates in the United States. All information collected through the Services, our website, and other interactions with us is processed and stored in the United States. By using the Services or submitting information to us, you consent to the transfer, processing, and storage of information in the United States.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify affected parties by posting the updated policy and, where appropriate, providing written notice (including by email). The "Last Modified" date at the top of this policy indicates when the most recent changes were made. Continued use of the Services or our website after any changes become effective constitutes acceptance of the updated Privacy Policy.
15. Contact
If you have questions about this Privacy Policy or our data practices, please contact us at:
The Better Money Company
228 Park Ave S.
PMB 256451
New York, NY 10003
Email: privacy@bettermoney.com